2025-03-28
Added · Updated
The Gibraltar Financial Services Commission issues this guidance to implement the Financial Services (Operational Resilience) Regulations 2023 for insurers, credit institutions, investment firms, and payment service providers. Regulated entities must identify important business services, set specific impact tolerances, and conduct scenario testing to ensure they can prevent, adapt to, and recover from severe operational disruptions. The document outlines requirements for governance, mapping, self-assessment, and reporting to maintain the stability of the Gibraltar financial system and protect clients.
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Version: 2
Publication Date: 28/03/2025 www.gfsc.gi
GFSC Guidance Note
Operational Resilience
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 2
Table of Contents
1 Introduction..................................................................................................................................... 3
2 Important Business Services............................................................................................................ 4
3 Impact Tolerances........................................................................................................................... 6
Impact tolerance metrics ................................................................................................................ 8
Actions to remain within impact tolerance..................................................................................... 9
4 Mapping......................................................................................................................................... 10
5 Scenario Testing ............................................................................................................................ 11
6 Self-assessment............................................................................................................................. 13
7 Governance ................................................................................................................................... 14
Board responsibilities.................................................................................................................... 14
Management responsibilities........................................................................................................ 14
8 Communications............................................................................................................................ 15
9 Outsourcing ................................................................................................................................... 15
10 Groups........................................................................................................................................... 15
11 The Relationship Between Operational Resilience and Operational Risk Policy .......................... 16
Risk Appetite and Impact Tolerances............................................................................................ 17
Financial Resilience........................................................................................................................ 17
12 The Relationship Between Operational Resilience and Business Continuity Planning (BCP) ....... 17
13 Implementation............................................................................................................................. 18
14 Supervisory review and feedback ................................................................................................. 18
15 Reporting an operational incident ................................................................................................ 18
Annex – Examples....................................................................................................................................... 20
Firm background............................................................................................................................ 20
How our example firms might identify important business services............................................ 20
How our example firms might set impact tolerances................................................................... 20
How our example firms may approach the mapping exercise...................................................... 21
How our example firms may conduct scenario testing................................................................. 21
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 3 1 Introduction
1.1 The purpose of this document is to provide guidance around the obligations set out in the Financial
Services (Operational Resilience) Regulations 2023 (the ‘Operational Resilience Regulations’). This Guidance Note is intended to complement existing legislation, policies and guidance and is not intended to conflict with, amend or supersede them.
1.2 The Operational Resilience Regulations apply to:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 4 2 Important Business Services
2.1 A business service is a service that a firm provides. Business services deliver a specific outcome or
service to an identifiable user external to the firm and should be distinguished from business lines, which are a collection of services and activities. Under the regulation 5(1)(a) of the Operational Resilience Regulations, firms must identify their important business services. Important business services are defined as the services a firm provides which, if disrupted, could:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 5 (6) the potential to inhibit the functioning of Gibraltar’s financial system; (7) the firm’s potential to impact the soundness, stability or resilience of Gibraltar’s financial system; (8) the possible impact on the firm’s financial position and potential to threaten the firm’s viability where this could:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 6
2.8 Important business services deliver a specific outcome or service to an identifiable user and should
be distinguished from business lines, such as mortgages, which are a collection of services and activities. They will vary from firm to firm. Firms should consider the chain of activities which make up the important business service, from taking on an obligation to delivery of the service, and determine those parts of the chain that are critical to delivery of the important business service. Critical parts of the chain are required to be operationally resilient, and firms should focus their work on the resources necessary to deliver them.
2.9 When assessing if boards and senior management can make prioritisation and investment decisions
for an important business service, firms are expected to consider whether the number of important business services is proportionate to their business. It is likely that larger firms will identify a larger number of important business services than smaller firms. 3 Impact Tolerances
3.1 The Operational Resilience Regulations require firms to set an impact tolerance for each of their
important business services. They define an impact tolerance as the maximum tolerable level of disruption to an important business service, as measured by a length of time in addition to any other relevant metrics.
3.2 When setting an impact tolerance for an individual important business service, firms must take into
account the impact of failure of other related important business services. These may be related because, for example, they share common resources which support the delivery of the important business services or where simultaneous disruption could have compounding impacts on similar external end users. Firms must take a proportionate approach in making this assessment, and only consider extra layers of complexity where there are significant benefits in terms of building operational resilience.
3.3 Impact tolerances provide a standard which boards and senior management should use for
prioritising investment, and making recovery and response arrangements. They may be helpful in informing decision-making during operational disruptions, when they would be considered alongside other information relevant to managing an incident effectively.
3.4 Impact tolerances must be set on the assumption that a disruption will occur. Firms should not
consider the cause or probability of disruption when setting their impact tolerances.
3.5 An impact tolerance must, in all cases, include a time-based metric to measure the tolerable level of
disruption to an important business service. Firms are also required to consider whether time-based impact tolerances should be used in conjunction with additional metrics, such as the volume or value of transactions that the firm can tolerate being interrupted for that period of disruption.
3.6 Firms may choose to set their impact tolerances by assuming an important business service is
unavailable for a specified period of time and judging the potential impact this would have. If this disruption would not:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 7 the firm could consider the impact of a longer disruption.
3.7 If, for example, the firm judges that after an important business service has been unavailable for five
days, there would be a risk to the firm’s clients, this would be the point within which the firm would set its impact tolerance.
3.8 The factors that a firm should consider when setting its impact tolerance include, but are not limited
to:
(1) the nature of the client base, including any vulnerabilities that would make the person more susceptible to harm from a disruption; (2) the number of clients that may be adversely impacted and the nature of the impact; (3) the potential financial loss to clients; (4) the potential financial loss to the firm where this could:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 8
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 9
3.16 When setting its impact tolerance, a firm should take account of the fluctuations in demand for its
important business service at different times of the day and throughout the year in order to ensure that its impact tolerance reflects these fluctuations and is appropriate in light of the peak demand for the important business service.
3.17 Impact tolerances should not consider the frequency at which operational disruptions are likely to
occur. Rather, should focus on setting the limit of the impact the firm can tolerate from a single disruption.
3.18 Setting an impact tolerance enables firms to assess the status of, and set resilience requirements
for, the necessary people, processes, technology, facilities, and information that contribute to the delivery of important business services. These requirements might include capacity specifications, recovery time, and point objectives which should be set to enable the firm to deliver the important business service within its impact tolerance.
3.19 There may be circumstances when a firm continuing to deliver a service through disruption may
have a more adverse impact than suspending it. An example of this is where the firm cannot sufficiently assure the integrity of data underpinning an important business service.
3.20 The Core Principles will remain relevant to decision making during operational disruptions,
including decisions about when an important business service is suspended or restored. When setting impact tolerances, the GFSC expects firms to consider the circumstances that might be prevailing at the time of the disruption to help them make informed recovery and response decisions and when they may decide not to resume the functioning of their important business services within the specified time. The GFSC expects firms should not be forced into inappropriate actions because of their impact tolerances in the event of a disruption. Actions to remain within impact tolerance
3.21 The Operational Resilience Regulations require firms to ensure they are able to deliver their
important business services within impact tolerances in severe but plausible scenarios. Mapping and testing the delivery of important business services will equip firms to establish whether and how they can remain within impact tolerances.
3.22 Firms are expected to take action where they identify a limitation in their ability to deliver
important business services within impact tolerances. Complicated business models or the provision of services across borders are unlikely to be considered as good reasons for a firm not to be able to act to ensure they can remain within an impact tolerance – these factors are themselves vulnerabilities that firms are required to address. However, incidents such as rapid technological change may be a reason for a firm to not be able to remain within an impact tolerance, as it may take time to improve resilience under those conditions.
3.23 Firms must develop and implement effective remediation plans for the important business services
that would not be able to remain within their impact tolerance. They must take prompt action where they cannot remain within the impact tolerance, so these plans should include appropriate timing for the necessary improvements.
3.24 In developing these plans to improve resilience, firms should consider the:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 10
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 11
4.6 Firms must update their mapping annually at a minimum, or following a material change if sooner.
5 Scenario Testing
5.1 The Operational Resilience Regulations require firms to regularly test their ability to remain within
impact tolerances in severe but plausible disruption scenarios. Impact tolerances assume a disruption has occurred, and so testing the ability to remain within impact tolerances should not focus on preventing incidents from occurring. Firms are required to focus on recovery and response arrangements.
5.2 Firms should identify the severe but plausible scenarios they use for testing. When setting scenarios,
firms could consider previous incidents or near misses within the firm, across the financial sector, and in other sectors and jurisdictions. A testing plan should include realistic assumptions and evolve as the firm learns from previous testing.
5.3 Firms are required to prepare a written self-assessment of compliance with the Operational
Resilience Regulations. Firms should document details of their scenario testing, including assumptions made in relation to scenario design and any identified risks to the firm’s ability to remain within impact tolerances.
5.4 Over time, a firm’s scenario testing is expected to become more sophisticated as firms develop
operational resilience for each important business service. Firms will be expected to test against more severe but plausible scenarios, proportionate to the firm and the degree of operational resilience each important business service has.
5.5 When considering the important business services to prioritise for testing, firms should consider the
relative risk they pose to:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 12 (4) the number of important business services tested – firms that have identified more important business services should undertake more scenario testing to reflect this; (5) the availability and integrity of supporting assets – impact tolerances are concerned with the continued provision of important business services. An important business service that can continue to be provided but has insufficient integrity should not be within a firm’s impact tolerance. Firms should test their recovery plans for both availability and integrity scenarios, proportionate to their size and complexity; (6) how the environment is changing and whether this could give rise to different vulnerabilities; and (7) how the firm expects to communicate with internal and external stakeholders effectively to reduce the harm caused by operational disruptions.
5.7 Scenario testing should not pose a material risk of creating a disruption. Where firms consider that
live-systems testing is most appropriate for scenario testing their ability to remain within impact tolerances, firms should assess the risk that the scenario testing may create a disruption to the delivery of important business services. Firms should conduct scenario testing with due skill, care, and diligence, act prudently, have effective risk strategies and risk management, and control their affairs responsibly and effectively.
5.8 The entire chain of activities that has been identified as the important business service should be
considered when developing testing plans.
5.9 The severity of scenarios used by firms for their testing could be varied by increasing the number or
type of resources unavailable for delivering the important business service, or extending the period for which a particular resource is unavailable. The mapping work that firms will undertake is likely to be useful in informing them how their scenarios could be made more difficult.
5.10 It would not be proportionate to require firms to be able to remain within impact tolerances in
circumstances which are beyond severe or are implausible. There will be scenarios where firms find they would not be able to deliver a particular important business service within their impact tolerance. For example, if essential infrastructure (such as power, transport, or telecommunications) were unavailable, some firms may not be able to deliver their important business services within their impact tolerance.
5.11 Firms should test a range of scenarios, including those in which they anticipate exceeding their
impact tolerance. Understanding the circumstances where it is impossible to stay within an impact tolerance will provide useful information to firms’ management and to the GFSC. Boards and senior management will need to judge whether failing to remain within the impact tolerance in specific scenarios is acceptable and be able to explain their reasoning to supervisors.
5.12 Where a firm relies on a third party for the delivery of its important business services, they should
work with the third party to ensure the validity of the firm’s scenario testing under Regulation 8(2). To the extent that the firm relies on the third party to carry out testing of the services provided by the third party to or on behalf of the firm, the firm should ensure the suitability of the methodologies, scenarios and considerations adopted by the third party in carrying out testing. The firm is ultimately responsible for the quality and accuracy of any testing carried out, whether by the firm or by a third party.
5.13 In carrying out the scenario testing, a firm should, among other things, consider the following
scenarios:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 13 (1) corruption, deletion or manipulation of data critical to the delivery of its important business services; (2) unavailability of facilities or key people; (3) unavailability of third party services, which are critical to the delivery of its important business services; (4) disruption to other market participants, where applicable; and (5) loss or reduced provision of technology underpinning the delivery of important business services. 6 Self-assessment
6.1 Firms are required to document a self-assessment of their compliance with the Operational
Resilience Regulations. Firms are expected to document the methodologies they have used to undertake these activities. Firms’ boards are accountable for and should approve the information provided in these documents. Boards and senior management should seek to build resilience so that they gain a high level of assurance that their firm is able to deliver its important business services within impact tolerances. Firms should document this information in the form of a self-assessment.
6.2 A self-assessment should directly address the requirements set out in the Operational Resilience
Regulations. Broader elements of firms’ operational resilience, for example, operational risk management and business continuity planning, should only be referenced where they directly pertain to the requirements under the Operational Resilience Regulations. Broader elements of firms’ resilience should be captured in existing firm practices.
6.3 When documenting a self-assessment, firms should:
(1) list their important business services and why each of these have been identified; (2) specify the impact tolerances set for these important business services and why each impact tolerance has been set; (3) detail their approach to mapping important business services, including how the firm has identified the resources that contribute to the delivery of the important business services and how they have captured the relationships between these. Firms should also document how they have used mapping to identify vulnerabilities and to support testing activity; (4) describe their strategy for testing their ability to deliver important business services within impact tolerances through severe but plausible scenarios. Firms should also describe the scenarios used, the types of testing undertaken, and specify the scenarios under which firms could not remain within their impact tolerances; (5) identify any lessons learned when undertaking scenario testing or via practical experience, including the actions taken to address the issues encountered or risks highlighted; (6) identify the vulnerabilities that threaten their ability to deliver important business services within impact tolerances. Firms should make every effort to remediate these vulnerabilities, detailing the actions taken or planned and justifications for their completion time. The
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 14 completion time should be appropriate to the size and complexity of the firm, and large and complex firms will be expected to take prompt action; and (7) identify any additional risks to their ability to deliver important business services within impact tolerances arising from elsewhere in their group. 7 Governance
7.1 The role of firms’ boards and senior management is central to compliance with the Operational
Resilience Regulations. Boards are accountable for and should approve the identification of their firms’ important business services and impact tolerances, and their self-assessments.
7.2 The ability of firms to deliver their important business services within their impact tolerances
depends on there being appropriate reporting and accountability in place throughout the firm. Where limitations are identified, leadership from firms’ boards and senior management is essential to prioritising the investment and cultural change required to improve operational resilience. Board responsibilities
7.3 Boards are specifically required to approve the important business services identified for their firm
and the impact tolerances that have been set for each of these. The Operational Resilience Regulations require that a firm’s board approve and regularly review the firm’s important business services, impact tolerances, and written self-assessment. In delivering this responsibility, boards must regularly review assessments of the firm’s important business services, impact tolerances, and the scenario analyses of its ability to remain within the impact tolerances for the important business services.
7.4 While individual board members are not required to be technical experts on operational resilience,
boards must ensure that they have the appropriate management information. Boards should also collectively possess adequate knowledge, skills, and expertise to provide constructive challenge to senior management and inform decisions that have consequences for operational resilience.
7.5 When assessing whether a firm’s board is meeting its wider obligations, the GFSC will consider
various matters relating to operational resilience, such as whether the board:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 15
7.8 Where a firm does not have a board, senior management should take responsibility for compliance
with the Operational Resilience Regulations.
8 Communications
8.1 Firms must develop communication strategies for both internal and external stakeholders as part of
their planning for responding to operational disruptions. These communication plans should be developed with a view to reducing harm to counterparties and other market participants, and supporting confidence in both the firm and financial sector.
8.2 As part of a firm’s communications strategy, a firm should:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 16 arising in parts of the group that are not subject to the individual requirements are taken into account.
10.2 When identifying important group business services, relevant entities are expected to consider
disruption to services in other entities within the group which could transmit risk to the safety and soundness of the relevant entity either directly or via the group. This includes, for example, where the relevant group has a subsidiary outside Gibraltar providing a service to customers which could, if disrupted, pose a risk to:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 17
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 18 13 Implementation
13.1 By 13 July 2024, firms must have identified their important business services and set impact
tolerances. In order to achieve this, and to identify any vulnerabilities in their operational resilience, firms should have mapped their important business services and commenced a programme of scenario testing.
13.2 Firms are not expected to have performed mapping and scenario testing to the full extent of
sophistication by 13 July 2024. Both mapping and scenario testing are ongoing processes, and firms are expected to perform them at varying levels of sophistication over time. Firms’ approaches to both mapping and scenario testing should evolve over time.
13.3 Firms are expected to have a prioritised plan which sets out how they will comply with the
requirement to be able to remain within their impact tolerances within a reasonable time, and no later than 13 July 2026. For a firm’s plan to be effective, firms must have started putting the plan into effect by 13 July 2024.
13.4 After 13 July 2026, maintaining operational resilience will be a dynamic activity. By this point, firms
should have sound, effective and comprehensive strategies, processes, and systems that enable them to address risks to their ability to remain within their impact tolerance for each important business service in the event of a severe but plausible disruption. 14 Supervisory review and feedback
14.1 The GFSC may provide a view or guidance on an individual basis during the course of its supervision
as to whether a firm’s compliance with the Operational Resilience Regulations and this Guidance Note is adequate and, if necessary, require a firm to take the necessary actions or steps to address any failure to meet the relevant requirements.
14.2 A firm should have regard to the views provided by the GFSC in relation to the firm’s compliance. If
a firm considers that any individual view or guidance given to it by the GFSC is inappropriate to its circumstances it should, consistent with Core Principle 12, inform the GFSC that it disagrees with that view or guidance. The GFSC may reissue the individual view or guidance if, after discussion with the firm, the GFSC concludes that the appropriate actions or steps a firm should take is different from that initially suggested by the GFSC.
14.3 If, after discussion, the GFSC and the firm still do not agree, the GFSC may consider other tools
available to it (including its powers under sections 69 and 70 of the Financial Services Act 2019) on its own initiative, to require the firm to take specific steps in line with the GFSC’s view to comply with the relevant Operational Resilience Requirements. 15 Reporting an operational incident
15.1 Under Core Principle 12, firms are required to deal with the GFSC in an open, cooperative and
timely way and to disclose to us any matter of which we would reasonably expect notice. This means that firms are required to report material operational incidents to the GFSC. An incident may be material if it:
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 19
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 20
Annex – Examples
Below, two fictional firms are used to illustrate how some elements of the Operational Resilience Regulations might apply to different types of firms. We acknowledge that in practice firms delivering business services would consider many other operational issues, dependencies, nuances in business models and risk management considerations. There examples are non-exhaustive and purely illustrative. Firms will need to consider how the elements apply to their own circumstances. Firm background Firm A is an electronic money institution with global operations, with core markets in Gibraltar, the UK and the European Economic Areas (EEA). It offers multiple payment products including electronic money 'e-wallet accounts' and pre-paid cards. Users based in Gibraltar and the UK make up about 20% of the firm’s daily active users and 25% of daily transactions. Firm B is an insurance intermediary that sells insurance products to retail customers to help them meet their specific needs. In addition, certain insurers have outsourced claims handling to Firm B and it holds claims money to be paid to customers under risk transfer agreements. Firm A offers its services mainly via its online portal as well as via agents in its contact centres. How our example firms might identify important business services Firm A identifies the provision of its multi-currency e-wallet account from which users can initiate electronic payment transactions as one of its important business services for the purposes of operational resilience. Users access their e-wallet account through the firm’s proprietary Apple and Android mobile apps. Access is via App only, there is no web-browser option. Firm A considers that loss of access to the e-wallet accounts can cause significant harm to its users, many of which are consumers, as that is the primary channel through which they manage payment transactions and interact with the firm. Firm B identifies claims handling for its customers as one of its important business services for the purposes of operational resilience. Firm B considers that disruption to the claims handling process could cause intolerable harm to consumers. For example, if consumers are unable to notify Firm B of their claim, submit a claim and/or and receive a claims payout/benefit under the policy. How our example firms might set impact tolerances Firm A - To set an impact tolerance relevant to its important business service of the provision of multicurrency e-wallet accounts from which users can initiate electronic payment transactions, Firm A considers the potential harm in the event of loss of its mobile app platform functionality. It identifies that consumer harm is the most relevant harm given the number of consumers affected and their reliance on the service for bill payments. Firm A quantifies the proportion of daily active users of its platform including the average volume of transactions and determines that there are a sizable number of consumers who may rely solely
on its service to manage their finances (including to make bill payments) and are therefore susceptible to greater detriment. Firm A also considers substitutability from the users’ perspectives and concludes that the unavailability of its e-wallet account will be particularly detrimental to users whose e-wallet accounts do not have card or ATM functionality, thereby leaving users with no alternative way to access
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 21 their funds. Using a time-sensitive metric, Firm A concludes that the appropriate impact tolerance is 2 hours to reflect the maximum disruption before there is an intolerable risk of consumer harm. Firm B has identified that disruption to its claims handling process for motor insurance could lead to potential consumer harm. For example, consumers being unable to obtain a courtesy car in a timely manner which could cause further disruptions in their lives. Firm B expects that consumers may want to notify them of a claim as soon as possible in order to progress their claim and obtain peace of mind. It further recognises that customers with courtesy car cover are likely to be seeking the courtesy vehicle soon after the accident. So, Firm B considers the maximum tolerable period for disruption to both their online portal and contact centre should be set at 2 days. Firm B considers it is important to have both channels available as some consumers may not have access to one channel or have preferences to use one channel over another. How our example firms may approach the mapping exercise Firm A conducts a mapping exercise to fully outline the underlying systems, technology and people, including material third party suppliers, and their interdependencies that enable its mobile platform app. From its mapping, Firm A concludes that its proprietary software engineering procedures and code enhancement (a core dependency) ensures resiliency by design including advance monitoring tools for early detection of availability and performance anomalies. Firm A also engages with critical third-party suppliers including data centre providers (Cloud Provisioning) where mobile app servers are hosted to understand their risk controls and agree a compatible service level agreement. It leveraged an existing map used for its annual business impact analysis during its mapping exercise. Firm B undertakes a mapping exercise of the resources that support the delivery of claims handling process. Firm A’s mapping reflects that it employs 180 contact centre agents (inbound call handlers) who work across two 7-hour shifts during office hours in their main office location, and have the appropriate technology to work from home if required. Firm B has identified most of the technology infrastructure including the online portal are hosted in the cloud provided by an external cloud service provider. The contact centre is located at the same location as the main office, and its technology and infrastructure are outsourced to a major telecom company where a service level agreement is in place. How our example firms may conduct scenario testing Firm A conducts regular reviews of resources that enable the delivery of its business services as part of its annual business impact analysis. It designs severe but plausible scenarios, considering the potential impact of loss of third-party provision, and engages
third parties to test the enablers of its e-wallet account provision for users. These tests indicate some residual risks and resilience gaps when faced with a severe but plausible scenario including those associated with channel of service delivery and cloud service provisioning by third parties. Following a review of lessons learned, Firm A provides a web channel as an additional service delivery channel to users as a back-up solution, and as an alternative in all eventualities. Among other actions, the firm also conducts a benchmarking exercise to identify alternate cloud providers with dispersed data centres across broader geographical spread where servers can be hosted to enable seamless continuity of service in all eventualities. It sets in motion plans to refresh its data protection policy to recognise cross-jurisdictional legal and regulatory requirements and develops a communication plan to advise users about alternative ways to access services and updates for service resumption.
Gibraltar Financial Services Commission Guidance Note on Operational Resilience 22 Firm B works with its cloud and contact centre infrastructure providers to design and test severe but plausible scenarios, considering the potential impact of cloud disruption, to ensure it can remain within its impact tolerance. During testing, Firm B has identified challenges with its contact centre provider, where there were significant dependencies on the provider’s sub-contractor based in a different country, and due to resource stretch and poor change management practices, the sub-contractor was unable to bring Firm B’s contact centre systems back online within the 2-day time frame. Firm B has also identified there was a significant backlog of cases after a disruption, and its current call handling resourcing plans were inadequate to deal with the backlog of cases. Firm B initiated a review to improve its controls over the monitoring and oversight of the contact centre provider. It also revisited its contractual terms and service level agreement (including the use of subcontractors) with the provider, to ensure appropriate service and support can be provided to enable Firm B to remain within tolerance. Firm B also updated its resourcing plans to allow additional call handlers to be brought in and trained up straight after an outage to minimise the backlog of cases.
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